Purpose

The purpose of this Anti-Corruption Policy is to establish guidelines and standards for preventing and combating corruption within our company in compliance with Swiss laws and regulations. We are committed to conducting our business with the utmost integrity, transparency, and adherence to anti-corruption practices.

Scope

This policy applies to all directors, employees, contractors, agents, and representatives of our company, regardless of their position or role, within the jurisdiction of Switzerland.

Prohibition of Corruption

Our company strictly prohibits any form of corruption, including but not limited to bribery, embezzlement, extortion, facilitation payments, or any other illicit activities intended to gain an unfair advantage.

Compliance with Swiss Laws

All employees must comply with the anti-corruption laws and regulations of Switzerland. This includes the Swiss Criminal Code, the Federal Act on Combating Corruption, and any other relevant Swiss legislation addressing corruption.

Gifts, Entertainment, and Hospitality

Employees should exercise caution when giving or receiving gifts, entertainment, or hospitality. Any such gestures should be reasonable, proportionate, and in compliance with Swiss laws. Gifts or benefits should never be offered or accepted if they could be perceived as an attempt to influence business decisions improperly.

Conflicts of Interest

Employees must avoid any situation that could create a conflict of interest between their personal interests and the interests of the company. This includes avoiding situations where personal relationships or connections could compromise the fair and objective decision-making process.

Due Diligence on Third Parties

Before engaging with third parties, such as suppliers, agents, consultants, or business partners, appropriate due diligence should be conducted to assess their integrity, reputation, and compliance with anti-corruption laws. We should only work with individuals and organizations that share our commitment to anti-corruption principles.

Reporting and Whistleblower Protection

We encourage employees to report any suspected or observed acts of corruption promptly. A confidential reporting mechanism will be established to allow employees to report concerns without fear of retaliation. Whistleblowers will be protected from any adverse consequences resulting from making a good faith report, in accordance with Swiss laws and regulations.

Training and Awareness

Regular training and awareness programs will be conducted to ensure that all employees understand their obligations under this policy and are equipped with the knowledge and tools necessary to prevent and identify potential instances of corruption.

Enforcement and Consequences

Any violation of this Anti-Corruption Policy may result in disciplinary action, up to and including termination of employment or contractual relationships. Additionally, individuals found to have engaged in corrupt practices may be subject to legal and regulatory actions in accordance with Swiss laws.

By adhering to this Anti-Corruption Policy, we demonstrate our commitment to maintaining the highest ethical standards and fostering a culture of integrity and accountability throughout our operations.

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